IRS Provides Guidance for Calculating the Subpart F Branch Rule’s Tax Rate Disparity Test

Overview


Lowell Yoder wrote this bylined article examining an IRS Chief Counsel Memorandum (CCM) which adopts a new approach for applying the tax rate disparity test under the Subpart F branch regulations. “The policy rationale behind this new approach is understandable, but the technical basis for it is not obvious from reading the regulations,” Mr. Yoder wrote. Read the full article